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Since the directive aims at enhancing shareholder engagement, thus transferring more power to shareholders, an effective cross-border shareholder identification system is an indispensable prerequisite for companies to meet this objective.
Given the lack of transparency of the accounts' structures (omnibus and nominee accounts) in many countries, any threshold could prevent effective shareholder identification.
Meaning, that unless companies are able to identify all end-investors (ultimate owners) they may not even be able to identify the shareholders holding more than 0.5 % of the shares. Also, given dispersed ownership of many companies, if a threshold is set at 0.5%, very few shareholders would be identified. For example, one of the large German blue-chip companies in the DAX30 currently has more than 200 000 shareholders in its register. If you set a threshold at 0,1% only between 30-50 shareholders would be identified, if at 0,5% not even 10 shareholders would be identified.
Therefore, in principle EuroepanIssuers opposes entirely any threshold on shareholder identification.
Nevertheless, EuropeanIssuers understands that certain Member States are strongly in favour of a threshold. EuropeanIssuers therefore tried to come up with a possible compromise that would take into account concerns of those Member States, while ensuring that shareholder identification could work for most of companies.